REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL Evolution of the sugar imports in the European Union from LDC and ACP countries Commission report referred to in Article 5 (3) of Commission Regulation (EC) No 828/2009
Date: 2013-05-31
Institutions: European Commission
Subjects: ACP countries, import (EU), least-developed country, originating product, sugar, tariff exemption, tariff quota

EUROPEAN 
COMMISSION 

Brussels, 31.5.2013  
COM(2013) 323 final 

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

Evolution of the sugar imports in the European Union from LDC and ACP countries 

Commission report referred to in Article 5 (3) of Commission Regulation (EC) No 
828/2009 

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TABLE OF CONTENTS 

1. 

2. 

3. 

4. 

4.1. 

4.2. 

4.3. 

5. 

6. 

7. 

Legal Framework ......................................................................................................... 3 

Introduction .................................................................................................................. 3 

New Sugar import context ........................................................................................... 4 

Evolution of sugar imports........................................................................................... 4 

Quantities of sugar imports .......................................................................................... 4 

Origin of sugar imports ................................................................................................ 5 

Raw versus white sugar imports .................................................................................. 5 

Supply and sugar price evolution................................................................................. 5 

Necessary market measures ......................................................................................... 7 

Conclusions .................................................................................................................. 7 

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REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND 
THE COUNCIL 

Evolution of the sugar imports in the European Union from LDC and ACP countries 

Commission report referred to in Article 5 (3) of Commission Regulation (EC) No 
828/2009 

1. 

LEGAL FRAMEWORK 

Article 9 of Council Regulation (EC) N° 1528/2007 of 20 December 2007 (the Market Access 
Regulation) applying the arrangements for products originating in certain states which are part 
of  the  African,  Caribbean  and  Pacific  (ACP)  Group  of  States  provided  for  in  agreements 
establishing,  or  leading  to  the  establishment  of,  Economic  Partnership  Agreements  (EPA) 
provides that for the period 1 October 2009 to 30 September 2015 imports of sugar from ACP 
states  which  are  not  Least  Developed  Countries  (LDC)  may  be  suspended  where 
simultaneously  sugar  imports  from  all  ACP's  exceed  3.5  million  tonnes  and  imports  from 
ACP  non-LDC's  exceed  1.6  million  tonnes  per  marketing  year.  This  quantity  has  been 
subdivided by region of production which guarantees minimum access for each EPA region. 
This is called the Transitional Safeguard Mechanism (TSM). 

Article 5 and Annex IV of Commission Regulation (EC) N° 828/2009 of 10 September 2009 
laying down detailed rules of application for the marketing years 2009/2010 to 2014/2015 for 
the  import  and  refining  of  sugar  products  of  tariff  heading  1701  under  preferential 
agreements,  provides  further  details  of  the  TSM.  Article  5  paragraph  3  states  that  "the 
Commission shall present a report on the functioning of the transitional safeguard mechanism 
for sugar". The report shall take account of sugar trade flows from ACP and LDC countries 
listed in annex I of this Regulation. 

2. 

INTRODUCTION 

In  2006  the  European  Union  reformed  its  sugar  regime  in  order  to  increase  the 
competitiveness and market orientation of the EU sugar industry. Key elements of this reform 
were a gradual 36% cut in the EU support prices for both the EU producers and ACP/LDC 
preferential  exporters  and  a  reduction  of  the  EU  quota  sugar  production.  The  2006  sugar 
reform took into account the preferential access for ACP and LDC sugar producers. 

During the reform it was estimated that, on the import side, a major role might be played by 
"swap"1 trade flows from preferential partners (ACP/LDC), under the hypothesis of a world 
white  sugar  price  of  USD  200  /tonne  and  an  exchange  rate  of  1.3  USD/€.  Under  these 

1 

In those estimates, it was underlined that " A major role might be played by "swap" trade flows, on the 
level of which remained a lot of uncertainty", due to the difficulties in organizing this scheme (i.e. all 
EBA sugar production had to be exported to the EU and EBA countries had to buy sugar needed for 
their consumption on the world market). Commission staff working document-reforming the European 
Union's sugar policy, SEC 2005, 0808 final, page 9.  

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assumptions, the difference between the EU sugar price and the world price, or the price in 
the ACP and LDC countries, might encourage some of these countries to export to the EU as 
much of their domestic production as possible by using swaps. 

Swaps depend on the gap between world and EU prices, freight costs and importers capacity 
to  organise  this  difficult  scheme.  During  the  reform  it  was  considered  that  the  potential 
maximum volume which could be "swapped" was 3.5 million tonnes, which corresponded to 
the ACP/LDC production capacity. 

3. 

NEW SUGAR IMPORT CONTEXT 

The  2009/10  marketing  year  was  the  first  year  of  implementation  of  a  complete  new  legal 
framework on imports. As from 1 October 2009 the ACP preferential import regime changed 
from the country allocated ACP "Sugar Protocol" quantities to Duty Free Quota Free imports 
under  the  Economic  Partnership  Agreement  (EPA)  and  Everything  But  Arms  (EBA) 
agreements, which expanded significantly ACP/LDC market access: LDC's sugar exports to 
the EU were fully liberalized and sugar imports from ACP's non LDC's partners were subject 
only to a safeguard measure based on volume.  

In  2009/2010,  ACP/LDCs  exports  to  the  EU  slightly  decreased,  but  as  from  2010/11,  we 
assisted  to  a  gradual  but  continuing  rise  in  these  exports.  World  market  prices  have  been 
particularly  high  over  the  last  3 years  and  the  EU  market  has  been  therefore  less  attractive; 
ACP/LDCs  taking  also  advantage  of  high  priced  local,  regional  and  world  markets. 
ACP/LDCs  exported  in  2011  worldwide  3.2  million  tonnes  of  sugar,  of  which  1.9  million 
tonnes  to  the  EU.  Moreover,  growth  of  production  and  exports  from  ACP/LDCs  has  been 
lower than expected due to some delay in on-going investments.  

Furthermore, since 2008 some ACP countries took a strategic decision to increase exports in 
the  form  of  white  sugar.  This  development  combined  with  growing  consumption  in  the 
ACP/LDC countries has reduced the volumes of raw sugar available for exports to the EU.  

In 2011, sugar consumption in the ACP/LDC countries was 7.3 million tonnes, compared to 
5.1 million tonnes in 2004, which represents an increase of 41% during this period.  

For details see table V in the annex. 

4. 

EVOLUTION OF SUGAR IMPORTS  

Following  the  2006  sugar  reform,  the  EU  changed  from  a  net  exporter  of  sugar  to  a  net 
importer. 

4.1. 

Quantities of sugar imports 

In the period between 2001/02 to 2005/06, average total sugar imports into the EU were 2.1 
million tonnes, of which 1.6 million tonnes from ACP/LDC countries. 

Since the marketing year 2006/07, total sugar shipments from third countries started to grow 
significantly, and during the 2010/11 marketing year sugar imports had already surged to the 

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unprecedented  level  of  3.7  million  tonnes  (+  77%  compared  to  the  period  2001/01  to 
2005/06),  the  highest  level  ever.  Meanwhile,  preferential  sugar  imports  from  ACP/LDC 
countries reached the level of 1.8 million tonnes (+ 16% in relation to the period 2001/01 to 
2005/06). 

In the marketing year 2011/12, overall imports of sugar into the EU were slightly lower than 
the previous marketing year, 3.6 million tonnes (- 3%). By contrast, preferential sugar imports 
from ACP-LDC countries continued to expand up to the level of 1.84 million tonnes (+1.9%, 
compared to the previous marketing year) setting a new record level. Therefore, preferential 
sugar imports have been growing continuously since the reform of 2006, although not to the 
extent expected in the most optimistic scenario, including swaps. 

For details on imports see annex I. 

4.2. 

Origin of sugar imports 

This  upward  trend  concerned  particularly  the  ACP/LDC  following  origins:  Mozambique, 
Swaziland, Malawi, Zambia, Zimbabwe, Laos and Cambodia. 

Based on current data it seems that the most promising LDC country for further expansion of 
sugar production and export to the EU is Mozambique. 

For details on imports see annexes II, III and IV.  

4.3. 

Raw versus white sugar imports 

The  previous  sugar  protocol  only  allowed  country  allocated  sugar,  mainly  raw  sugar  for 
refining. Therefore one of the major new elements since the reform of the sugar regime was 
the  possibility  to  import  white  sugar.  And  indeed  some  ACP  countries,  notably  Mauritius, 
have increased exports of white sugar compared to raw sugar, to reap the higher added value. 

In marketing year 2011/12, raw sugar imports into the EU surged to a new record level of 2.7 
million tonnes representing 76% of the total volume imported. 

For details on imports see annex I. 

5. 

SUPPLY AND SUGAR PRICE EVOLUTION  

Supply evolution 

During the 2006/07 and 2007/08 marketing year, the EU sugar market was over supplied and 
the EU was obliged to withdraw quota sugar from the market. This surplus market situation 
lasted until the beginning of the 2008/09 marketing year. As of the marketing year 2009/10, 
the EU sugar market turned from an over-supplied market to a more balanced market. Whilst 
the open access for ACP/LDC countries created new opportunities for EU operators to source 
sugar,  it  also  induced  downward  pressure  on  EU  sugar  prices.  However,  due  to  this 
development  in  combination  with  increasing  world  market  price,  some  EU  importers 
experienced difficulties to contract their supply needs. In the course of the calendar year 2011, 
it became evident that the EU sugar market was not an oversupplied market but rather a tight 

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market. Therefore, as of the 2011/12 marketing year, sugar prices were negotiated in this new 
economic  environment  and  the  sugar  producers  managed  to  negotiate  much  higher  sugar 
prices for the EU market. 

Price evolution 

During the transitional period between July 2006 – September 2009, the EU internal white 
sugar price declined by 12%, falling from EUR 630 per tonne to EUR 555 per tonne.  

During the period October 2009 – February 2010, imports were coming in at the expected 
rate,  in  accordance  with  EPA/EBA  monitoring  system.  As  a  result,  the  EU  internal  price 
dropped  from  EUR  555  per  tonne  in  September  2009  to  EUR  493  per  tonne  in  November 
2009  (-11%),  despite  the  temporary  increase  of  the  world  market  prices  which  in  February 
2010 reached a 30-year record high of EUR 522 per tonne. 

During the following months, world market prices started to decline, with a sharp fall between 
February  and  May  2010,  from  EUR  522  tonne  to  EUR  376  tonne  (-28%).  During  this 
period, EU internal market prices stabilised around EUR 475 tonne. 

However, world market prices displayed a sharp increase throughout the second semester of 
2010,  reaching  levels  above  the  EU  price  through  September  2010-  January  2011:  in 
December  2010,  the  world  market  white  sugar  price  was  much  higher  than  EU,  EUR  628 
tonne compared to EUR 486 €

 tonne.  

During the first semester 2011, the EU and the world market went in opposite directions, and 
by May 2011 world market prices had fallen from EUR 628 tonne to EUR 400 tonne, driven 
by  abundant  supply  on  the  world  market.  Meanwhile,  during  the  same  period  EU  price 
increased from EUR 486 tonne to EUR 536 tonne. 

The prospect at the beginning of the marketing year 2011/12 had changed. It was clear that 
the  import  concessions  awarded  to  ACP  and  LDC  through  the  EPA/EBA  agreements,  were 
not generating excessive import flows. Previous expectations that the EU sugar market may 
be flooded by ACP/LDC sugar showed not to be realistic, and the prospect was that imports 
from the ACP and LDC countries would not be able to cover the gap between EU (in quota) 
production and demand. As a result, EU sugar prices started to increase considerably above 
the world market price, even beyond the level prior to the implementation of the 2006 reform 
and contrary to the continuous decline in the world market prices since the beginning of 2011. 
Therefore,  during  the  year  2012  the  EU  price  increased  uninterruptedly,  reaching  the  high 
level of EUR 738 tonne in January 2013. 

For details see graph in annex VIII. 

6. 

NECESSARY MARKET MEASURES 

Paradoxically, during the last marketing years, instead of applying the transitional safeguard 
mechanism the Commission had to find ways to allow additional sugar into the EU market in 

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order  to  fill  the  supply  gap  on  the  EU  sugar  market  for  food  purposes  (i.e.  the  EU  quota 
market). The EU can choose between two sources of supply: 

• 

• 

Release of out-of quota sugar on the internal market 

Allow additional imports 

In the marketing year 2010/11 a total additional quantity of 1.35 million tonnes of sugar was 
supplied to the EU market of which: 

• 

• 

• 

500  000  tonnes  release  of  out-of-quota  sugar  at  zero  tariff  (and  26.000 
tonnes of iso-glucose) 

500 000 tonnes of additional imports within a zero duty TRQ  

350 000 tonnes were allowed in tenders at reduced duty 

In the marketing year 2011/12, 1 million tonnes of additional sugar was supplied to the EU 
market of which:  

• 

• 

• 

400  000  tonnes  release  of  out-of-quota  sugar  (and  21.000  tonnes  of  iso-
glucose) at a tariff of EUR 85/tonne 

250  000  tonnes  release  of  out-of-quota  sugar  (and  13.000  tonnes  of  iso-
glucose) at a tariff of EUR 211 /tonne 

399 000 tonnes of sugar imports at reduced duty (including 15 000 tonnes of 
white sugar)  

7. 

CONCLUSIONS 

In the framework of the 2006 reform, it was forecasted that under very particular conditions 
the  EU  sugar  market  might  be  flooded  with sugar  from  the  LDC  countries.  Two  conditions 
were  necessary:  (1)  a  large  gap  between  EU  price  and  world  price  and  (2)  capacity  in 
organising  a  complex  scheme  leading  to  export  local  production  from  the  LDC  sugar 
producing  countries  and  importing  a  similar  quantity  from  the  world  market  to  satisfy  their 
domestic needs. 

Following  2009  import  liberalisation,  very  few  countries  seem  to  have  succeeded  in 
organising such a complex trade scheme. Nevertheless sugar imports from those origins have 
reached record levels, although not at a level that would have triggered safeguard measures, 
during the marketing years 2009/2010 to 2011/2012. 

Until  the  end  of  the  2014/15  marketing  year,  the  maximum  level  of  sugar  imports  from 
ACP/LDC countries is expected to be in the range of 2.1 – 2.2 million tonnes. Therefore, it is 
highly unlikely that the safeguard measures will be triggered during its application period.  

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ANNEX I 

EU27 SUGAR IMPORTS BY MARKETING YEAR (OCT-SEPT) -  CN 1701 IN TONNES

2001-02

2002/03

2003-04

2004-05

2005-06

Average 
2001/02  
2005/06

2007-08

2008-09

2009-10

2010-11

2011-12

ACP and LDC
of which ACP

EBA-LDC (1)

CXL (2)
Balkan
Other Origins

1.531.465

1.485.563

1.386.191

1.605.650 1.471.504 1.583.673 1.570.403 1.544.446 1.555.135 1.518.806 1.886.113 1.521.920 1.807.498 1.842.447
1.784.101
1.455.616
58.346
594.749 1.219.176 1.196.580
359.399
344.124
340.942
152.576
315.949
58.484

1.854.121
31.992
770.933
356.360
134.946

1.496.276
22.530
715.275
356.268
106.794

127.272
82.899
394.013
201.681

112.718
82.899
492.334
178.838

85.313
82.899
325.407
86.102

74.185
82.899
205.559
70.649

98.110
82.899
91.979
153.752

99.520
82.899
301.858
138.204

1.742.997
64.500

1.469.558
52.362

1.417.174

1.457.685

EU TOTAL IMPORTS 1.964.757 1.965.912 1.912.303 2.324.474 2.223.039 2.078.097 2.697.142 3.148.352 2.516.096 3.686.747 3.551.002

of which  raw sugar

white sugar

(1) Laos, Cambodia,Nepal, Bangladesh.

(2) Brazil, Cuba, Australia, India (India before 2005 was in the ACP protocol)

2.205.305
491.837

2.623.549
524.803

1.930.752
585.344

2.563.972
1.122.775

2.703.252
847.750

Source: Eurostat Comext database

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ANNEX II 

REG. (CE) n° 828/2009  -  PREFERENTIAL EPA-EBA AGREEMENTS SUGAR
IMPORT LICENCES FOR SUGAR AND SUGAR PRODUCTS

CERTIFICATS D'IMPORTATION POUR LE SUCRE ET LES PRODUITS DU SECTEUR SUCRE

October 2009    September 2010

(tonnes white sugar equivalent)

CUM ULAT E D ALLO CAT E D Q UAN T IT IE S BY M E M BE R ST AT E  AN D O RIGIN

Quota

Me mbe r S ta te s

N r

origin

BE

BG

CZ

D K

D E

E E IE

E L

ES

FR

IT

CY LV LT LU H U MT

N L

AT

P L

P T

R O

S I SK

FI

S E

U K

T OT AL

09.4221 Bangladesh

2 000

1 040

500

Cambodia
Laos
Nepal

09.4231 Benin

Burkina Faso
Dem. Rep.Congo
Ethiopia
Madagascar
Malawi
Mozambique
Senegal
Sierra Leone
Sudan
Tanzania
Togo
Zambia

09.4242 Ivory Coast

26 756

4 447

1 001

17 335
11 712

1 347

987

23 051

9 169

5 674
57 236

4 450

63 301

959

1 189

09.4243 Swaziland

215

43 676

42 250

25

28 800

215

54 300

59 120

66 228

09.4244 Kenya

09.4245 Mauritius

Zimbabwe

09.4246 Fiji

09.4247 Barbados

Belize
Dominican Republi
Guyana
Jamaica
Trinidad & Tobago

6 042

547

389

80

118 047

1 346

145

145 824

4 702

901

2 340

1 520

25 607
35 330

973
25 225

62

20

173

44

31 850
17 600

9 850
38 450

16 123
20 580

20 000

3 540
9 850
38 450

9 169

26 756
49 062
89 528

4 450
20 000

6 674

93 026

47

47

4 282

299 110

410

410

43 615
8 850

352 332
69 405

100 300

100 300

23 500
65 612
433
106 750
59 200

23 500
65 612
433
138 644
76 800

Cumula te d tota l

10 489

29 518

389

80

162 724

2 386

94 493

145 849

35 393 215

901

3 327

55 820

309 338

92 426

62

979

1 361

524 675

1 470 425

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ANNEX III 

REG. (CE) n° 828/2009  -  PREFERENTIAL EPA-EBA AGREEMENTS SUGAR
IMPORT LICENCES FOR SUGAR AND SUGAR PRODUCTS

CERTIFICATS D'IMPORTATION POUR LE SUCRE ET LES PRODUITS DU SECTEUR SUCRE

October 2010    September 2011

(tonnes white sugar equivalent)

CUM ULAT E D ALLO CAT E D Q UAN T IT IE S BY M E M BE R ST AT E  AN D O RIGIN

Quota

Me mbe r S ta te s

N r

origin

BE

BG

CZ

D K

D E

EE IE

E L

ES

FR

IT

CY LV LT LU H U MT

N L

AT

PL

PT

R O

S I SK

FI

SE

U K

T OT AL

09.4221 Bangladesh

Cambodia
Laos
Nepal

09.4231 Benin

Burkina Faso
Dem. Rep.Congo
Ethiopia
Madagascar
Malawi
Mozambique
Senegal
Sierra Leone
Sudan
Tanzania
Togo
Uganda
Zambia

09.4242 Ivory Coast

09.4243 Swaziland

09.4244 Kenya

9 601

6 107

40

30 962

5 484

3 005

15 858
38 412

212

20 000

690
4 830
43 728

1 700

1 039
14 781

7 066
60 564

342

22 000
41 380

22 000
41 380

417
24 293

10 417

1 126

2 544
9 830

9 312

8 488

690
50 007
126 680

1 700
20 000

485

24 827

12 952

5 112

8 589
149 580

59 160

24 650

5 278

12 586

263 930

09.4245 Mauritius

3 192

561

474

99

Zimbabwe

09.4246 Fiji

09.4247 Barbados

Belize
Dominican Republi
Guyana
Jamaica
Trinidad & Tobago

45 796

43 800

270 774
3 940

1 637

1 910
34 300

86 073

72 659

14 959

3 599
10 103

22

1 610

1 594

1 855

21
80 868

1 342
10 000

108

203

6 460

9 682

38 496
20 786

14 959

43 614
19 531

418 691
158 742

136 600

136 600

11 941
72 038

21 623
72 038

130 146
70 748

175 102
91 534

Cumula te d tota l

12 833

561

474

99

357 580

1 637

155 584

113 087

222 903

22

2 095

1 594

85 842

199 213

39 989

108 1 126

12 577

575 008

1 782 333

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ANNEX IV 

REG. (CE) n° 828/2009  -  PREFERENTIAL EPA-EBA AGREEMENTS SUGAR
IMPORT LICENCES FOR SUGAR AND SUGAR PRODUCTS

CERTIFICATS D'IMPORTATION POUR LE SUCRE ET LES PRODUITS DU SECTEUR SUCRE

October 2011    September 2012

(tonnes white sugar equivalent)

CUM ULAT E D ALLO CAT E D Q UAN T IT IE S BY M E M BE R ST AT E  AN D O RIGIN

Quota

Me mbe r Sta te s

N r

origin

BE

BG

CZ

D K

D E

E E IE

E L

E S

FR

IT

CY LV LT LU H U MT

N L

AT

PL

PT

R O

S I SK

FI

S E

U K

T OT AL

09.4221 Bangladesh

Cambodia
Laos
Nepal

09.4231 Benin

Burkina Faso
Dem. Rep.Congo
Ethiopia
Madagascar
Malawi
Mozambique
Senegal
Sierra Leone
Sudan
Tanzania
Togo
Uganda
Zambia

09.4242 Ivory Coast

09.4243 Swaziland

09.4244 Kenya

09.4245 Mauritius

Zimbabwe

09.4246 Fiji

09.4247 Barbados

Belize
Dominican Republi
Guyana
Jamaica
Trinidad & Tobago

8 105

1 017

17 359
12 327

28 588
61 280

65

16 203
113 099

1 500

292

399

6 974

29 514

113

35 139

27 405

9 065

12 570

1 653

399
122 432

15 000
41 530

15 000
41 530

9 775

15 182
9 852

24 400

9 793
19 628

20 522

20 388

4 911

8 532
1 314

1 895

1 460

7 567
10 006

14 686

25 891
101 914
238 265

3 395
40 910

115 658

74 146

975

90 198

1 507

5 805

8 854

48 300

16 242

361 685

8 318

298

664

101

259 151

1 842

1 354

5 204

8 055

66

1 029
25 328

1 849

2 852

821
61 838

2 182
24 605

87

269

41 733
34 000

335 875
145 771

19 397

38 906

19 375

21 576

16 965

17 075
630

100 978

100 978

21 750
78 423

97 554

21 750
95 388

114 629
99 884

Cumula te d tota l

16 422

20 713

664

101

411 469

1 842

194 883

7 857

301 600

66

47 930

1 849 103 193

149 424 137 467

87

16 652

1 729

466 437

1 880 385

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ANNEX V 

CONSUMPTION

2004

2005

2006

2007

2008

2009

2010

2011

LDC not ACP

1.095.000

1.225.000

1.360.000

1.460.000

1.575.000

1.677.500

1.765.000

1.860.000

TOTAL ACP

4.053.966

4.420.869

4.536.894

4.597.828

4.830.907

5.187.183

5.358.832

5.404.366

Total LDC+ACP

5.148.966

5.645.869

5.896.894

6.057.828

6.405.907

6.864.683

7.123.832

7.264.366

Source: ISO, raw value.

ANNEX VI 

PRODUCTION

2004

2005

2006

2007

2008

2009

2010

2011

LDC not ACP

265.000

250.000

280.000

310.000

260.000

225.000

275.000

305.000

TOTAL ACP

6.119.767

5.928.438

5.926.168

5.748.037

5.650.445

5.859.932

5.677.900

6.154.852

Total LDC+AC 6.384.767

6.178.438

6.206.168

6.058.037

5.910.445

6.084.932

5.952.900

6.459.852

Source: raw value

2004

2005

2006

ANNEX VII 

EXPORT
2007

2008

2009

2010

2011

LDC not ACP

214.960

280.000

220.000

140.000

252.751

463.141

431.476

378.006

TOTAL ACP

2.923.344

2.773.966

2.840.530

2.612.995

2.629.260

2.391.984

2.443.570

2.847.671

Total LDC+ACP

3.138.304

3.053.966

3.060.530

2.752.995

2.882.011

2.855.125

2.875.046

3.225.677

Source: ISO, International  Sugar Organization (raw value).

EN 

12 

EN 

 
  
 
 
 
ANNEX VIII 

EU and world sugar price 

EN 

13 

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